I’m all for looking after children and making sure that their play experience is as safe and worry-free as possible but do we really need regulations that think so little of a parent’s own common sense? As of the thirtieth of September a new testing requirement will come into force for toys sold in the UK, this one is about sound (I found out about this in Robert Hutchins‘ article in Toy News). I’ve worked in toys for a fair portion of my life and I’ve yet to encounter any harm coming to a child as the result of a musical/noise toy, more so I’ve not even had a customer complain about the sound levels of a toy, not once, in over fifteen years, not once. This isn’t to say damage can’t be done just that anecdotally I haven’t come across any. I should also point out that there are already safety regulations regarding acceptable noise levels in toys.
So lets look at the ‘why’ of this change to legislation over toy safety, is there legitimate cause for concern? According to the US environmental protection agency, sounds over 85db (decibels) can cause damage and they recommend ear protection in environments where sound at that level might be encountered. So what noises might count? Well a washing machine apparently runs at 75db falling short of the need for ear protection and normal human speech falls somewhere between 55db and 65db so lets just take this in for a second. The new regulations include a range of toys designed to be used at a fair distance from a child’s ear so apparently we now need to test if these toys can produce sounds louder than a washing machine.
I have never encountered a toy that can produce more noise than a washing machine. Even a toy drum (probably the noisiest toy I can think of), though it may be hard to talk over, is not even close to the volume of a washing machine. Even a washing machine is 10db shy of causing problems for your ears, so these ‘dangerous toys’ must be pretty impressive, somehow producing sounds which approach the same volume as heavy city traffic (85db) or a petrol-powered lawn-mower (95db). I have no idea what these new toys (that must have prompted this new addition to toy safety testing) must look like and I’m not sure I want to know.
You can be safe in the knowledge that no-one involved selecting the toys we sell at Fun Junction would ever choose to stock a toy that could rival city traffic or a petrol-powered lawn mower in terms of volume level, whether they passed safety testing or not. If nothing else we’d be stuck listening to them throughout our day (we get previews of all our ‘noisy’ toys all the time, as kids play about and sample the toys on the shelves, it’s part of the job).
Noise exposure (we’re talking things as loud as a nearby airport here) has also been found to produce cognitive impairment and memory problems for children. You can check out this paper from the health protection agency in the UK from 2010, the content on p63 (p73 on the pdf) deals specifically with the effect of noise on learning and memory. So apparently hearing loss isn’t all we have to worry about in relation to load noises around children, the impact of sound on a child’s development isn’t to be taken lightly.
This is something to be careful of and I’m not going to ignore the fact that proximity to your ear will also change the effects of noise exposure, as the US environmental protection agency‘s ‘Sound Thermometer’ shows a walkman (maybe we should just call it an MP3 player now, ‘walkman’ seems a bit out of date) can produce 105db of sound directly into your ear. With this in mind then of course we need to be wary of the kinds of sounds children are exposed to (not just their raw background decibel level) but I’m not sure if further regulation was necessary in the case of toys that don’t utilise headphones/earphones.
Even a few feet away from your ear the sound from small headphone speakers on full blast can start to resemble a whisper (15db-25db) so there is a high level of relativity when it comes to the way sound meets the ear. Holding a toy phone directly to your ear means that in order to be safe the speaker will have to produce a lower volume than you might otherwise find (e.g. on a toy where close proximity to an ear is unlikely). Toy companies which produce close to the ear toys already have to meet regulations regarding proximate decibel level but this new change to safety regulations means that things like toy drums etc. will have to be tested in new ways.
I’m not advocating that we ignore the potential side-effects of noise on a child’s ears but it’s important to remember that the people buying these toys are responsible adults. I wouldn’t buy a toy phone for my kids that was louder than my own phone and I certainly wouldn’t buy any toy loud enough to drown out our washing machine. One of the duties of a parent is to look out for our child(ren)’s safety, surely we can rely on parental choice and already existing controls on the volume of sounds in toys. The only positive thing I can see coming about as the result of this new regulation is that the regulators will have more to do and there will be more money to be made.
From what I’ve heard normal safety testing can cost between £1000 and £10,000 per toy type (if any significant change is made to a toy, or importantly if regulations change, it will also need to be retested). (N.B. Please let me know if I’ve got these costs wrong). As with anything the cost goes down the more you get, with this in mind smaller companies already have a hard time factoring the cost of testing into their toy whilst still making the retail price reasonable. Further regulation will only hinder these companies more. I’ve lost count of the number of local toy makers we’ve had to turn away because we legally can’t sell an uncertified toy product in a toy shop. The only way these people can sell their (often fantastic) toys is to market them as ‘craft’ or ‘gift’ items and even then things can be tricky for them.
It’s a sad world and it’s getting sadder, I can only hope that this madness will end soon and small companies (and even start-ups) might get a chance to sell their toys as toys. What do you think? Is regulation like this important and unavoidable or do you think people could get by without it (or at least with the regulation relaxed significantly)? As always I welcome any views/perspectives, feel free to comment in the box below or pop over to my twitter page and chat about it over there. Thanks for reading, all the best, John